Title
Manay, Jr. vs. Cebu Air, Inc.
Case
G.R. No. 210621
Decision Date
Apr 4, 2016
Passengers failed to review flight tickets for 37 days, leading to denied boarding; Supreme Court ruled no damages due to their negligence.

Case Digest (A.C. No. 5239)
Expanded Legal Reasoning Model

Facts:

  • Ticket Purchase
    • June 13, 2008: Carlos S. Jose purchased 20 Cebu Pacific round-trip tickets from Manila to Palawan at Robinsons Galleria, specifying departure on July 20, 2008 at 08:20 and return on July 22, 2008 at 16:15; paid ₱42,957 via credit card.
    • Agent (Alou) printed three-page tickets and recapped only the first page; Jose did not read the remaining pages.
  • Travel Incident
    • July 22, 2008: Upon check-in for the return flight, nine passengers were denied boarding because their tickets showed a 10:05 departure; the group had to rebook at an extra ₱7,000 per ticket, paying ₱65,000 in cash and leaving four behind overnight (incurring ₱5,205 in additional ticket and accommodation expenses).
    • Post-incident: Jose sent demand letters (September 3, 2008; January 20, 2009) seeking reimbursement of ₱42,955; filed a DTI complaint; Cebu Pacific replied by e-mail claiming full recap had been given.
  • Judicial Proceedings
    • MTC Mandaluyong (Dec. 15, 2011): Ordered Cebu Pacific to pay ₱41,044.50 actual damages and ₱20,000 attorney’s fees for failing to exercise extraordinary diligence in ticketing.
    • RTC Mandaluyong (Nov. 6, 2012): Affirmed MTC’s findings but deleted attorney’s fees for lack of Civil Code Article 2208 basis.
    • CA (Dec. 13, 2013): Reversed lower courts; held passenger negligence in failing to review flight details; denied Cebu Pacific’s counterclaim.
    • SC proceedings: Petitioners filed a Petition for Review on Certiorari with a disputed extension of time; SC chose to relax procedural rules and hear the merits.

Issues:

  • Whether the Supreme Court should grant the requested extension of time for filing the petition for review on certiorari.
  • Whether Cebu Pacific, as a common carrier, is liable for damages arising from issuance of tickets with an erroneous return flight schedule.
  • Whether petitioners are entitled to actual, moral, and exemplary damages, and attorney’s fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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